Facts:
20th Century Fox Film Corporation filed a letter-complaint dated August 26, 1985 with the
National Bureau of Investigation (NBI) alleging widespread unauthorized sale and rental of copyrighted films in videotape form across Metro Manila in violation of
Presidential Decree No. 49. The NBI conducted surveillance and, relying on its investigation and depositions of its agents and the petitioner's counsel, filed consolidated applications for three search warrants with the
Regional Trial Court of Makati, Branch 132 against the video outlets owned by
Eduardo M. Barreto,
Raul M. Sagullo, and
Fortune Ledesma. The trial court issued the warrants on September 4, 1985, after which NBI agents, accompanied by the petitioner's agents, executed raids and seized numerous items described in the warrants and left inventories with the private respondents. The private respondents moved to lift the warrants and for return of seized property; the trial court, finding the NBI and its witnesses lacked personal knowledge and that critical proof such as master tapes had not been presented and that the warrants were overly general, issued an order dated October 8, 1985 lifting Search Warrants Nos. SW-85-024, SW-85-025, and SW-85-026 and ordering return of certain seized items; the trial court denied reconsideration on January 2, 1986. The petitioner sought certiorari relief in the
Court of Appeals, which dismissed the petition, and the petitioner then filed the present petition for review with the Supreme Court, decision rendered August 19, 1988.
Issues:
Did the trial court err in lifting the three search warrants for lack of probable cause as required by the Constitution? Was the presentation of the original or master tapes at the warrant application stage necessary to establish probable cause to search and seize allegedly pirated videotapes and related equipment?
Ruling:
Ratio:
Doctrine: